Issues: (i) Whether the additional legal grounds could be admitted. (ii) Whether the assessments were valid where the common satisfaction note did not show the seized material's bearing on total income for the relevant assessment years.

Issue (i): Whether the additional legal grounds could be admitted.

Analysis: The additional grounds raised legal questions going to the root of the matter and required no fresh investigation of facts. Such grounds may be admitted under the applicable appellate principle.

Conclusion: The additional legal grounds were admitted in favour of the assessee.

Issue (ii): Whether the assessments were valid where the common satisfaction note did not show the seized material's bearing on total income for the relevant assessment years.

Analysis: Jurisdictional satisfaction under section 153C requires the note to disclose that the seized incriminating material bears on determination of the other person's total income. The common note covering multiple assessment years did not make that connection clear for those years.

Conclusion: The assessments under section 153C were quashed in favour of the assessee.

Final Conclusion: The additions made through the invalid assessments cannot survive.

Ratio Decidendi: A satisfaction note under section 153C must demonstrate that seized material has a bearing on the other person's total income for the relevant assessment years.

Issues: Whether penalty proceedings for furnishing inaccurate particulars are valid where the show-cause notice does not specify the applicable limb of Section 271(1)(c).

Analysis: A penalty notice issued under Section 271(1)(c) read with Section 274 must clearly identify the precise charge invoked. Failure to specify the relevant limb renders the penalty proceedings invalid.

Conclusion: The deletion of penalty was sustained; the issue was decided in favour of the assessee.

Issues: Whether assessments under Section 153C were valid where the satisfaction recorded by the Assessing Officer of the searched person did not identify the seized material as belonging to, pertaining to, or relating to the assessee.

Analysis: Section 153C requires a valid satisfaction establishing the requisite nexus between the seized material and the other person. The satisfaction recorded in the searched person's case did not specify whether the material belonged to, pertained to, or related to the assessee. Applying strict interpretation of the jurisdictional requirement, this deficiency was fatal to assumption of jurisdiction under Section 153C.

Conclusion: The assessments under Section 153C were invalid for want of a valid satisfaction and were quashed.

Issues: Whether the amount received by BSNL employees under the BSNL Voluntary Retirement Scheme, 2019 is to be treated as retrenchment compensation and a capital receipt exempt from tax.

Analysis: The Tribunal followed its earlier coordinate-bench decision on identical facts and held that the compensation paid under the BSNL Voluntary Retirement Scheme, 2019 was in substance retrenchment compensation. It accepted the view that the receipt fell within the exempt category and that the earlier findings of the first appellate authority could not stand in view of the binding and consistent tribunal precedent.

Conclusion: The compensation was held to be exempt from tax, and the assessee's claim succeeded.

Issues: (i) Whether assessments under Section 153C could rest on a satisfaction note stating that seized documents "belonged to" the other person, rather than that they "pertained to" or "related to" that person; (ii) Whether the assessment for AY 2014-15 fell outside the permissible ten-assessment-year period; (iii) Whether the assessment for AY 2017-18 could survive where the addition was below the applicable Rs. 50 lakh pecuniary threshold.

Issue (i): Whether assessments under Section 153C could rest on a satisfaction note stating that seized documents "belonged to" the other person, rather than that they "pertained to" or "related to" that person.

Analysis: Section 153C(1)(a) applies the expression "belongs to" to seized money, bullion, jewellery or other valuable articles or things. Seized documents and books of account are governed by Section 153C(1)(b), which requires statutory satisfaction that they pertain to or relate to the other person. The Satisfaction Note employed the expression "belongs to" for documents. On strict construction of taxing statutes, this did not meet the applicable jurisdictional requirement.

Conclusion: The assessments founded on the defective Satisfaction Note were non est and were quashed in favour of the assessee.

Issue (ii): Whether the assessment for AY 2014-15 fell outside the permissible ten-assessment-year period.

Analysis: The Section 153C notice was issued on 16.05.2023. Under Explanation 1 to Section 153A, computation of the ten assessment years from the end of AY 2024-25 placed AY 2014-15 beyond the jurisdictional time limit.

Conclusion: The assessment for AY 2014-15 was outside the permissible period and was quashed in favour of the assessee.

Issue (iii): Whether the assessment for AY 2017-18 could survive where the addition was below the applicable Rs. 50 lakh pecuniary threshold.

Analysis: The sole addition was Rs. 3,17,540, substantially below the applicable Rs. 50 lakh pecuniary threshold.

Conclusion: The assessment for AY 2017-18 could not be sustained and was quashed in favour of the assessee.

Final Conclusion: The search assessments were unsustainable because the statutory satisfaction for seized documents was defective, one assessment year lay beyond the permissible look-back period, and the remaining assessment involved a below-threshold addition.

Issues: Whether the assessment order passed under Section 73 of the Kerala State Goods and Services Tax Act, 2017, on the basis of alleged mistaken adjustment of input tax credit between IGST and CGST/SGST heads, was sustainable in view of the earlier Division Bench decision.

Analysis: The petitioner's challenge to the assessment was accepted on the ground that the controversy stood covered by an earlier Division Bench ruling of the Court in favour of the petitioner. The Court treated that decision as governing the present dispute and proceeded to grant relief accordingly.

Conclusion: The impugned assessment order was quashed, and the writ petition was disposed of in favour of the petitioner.

Final Conclusion: The demand-based order could not survive in light of the binding earlier decision, though the State was left at liberty to seek resolution of inter-departmental settlement issues through the GST Council.

Issues: (i) Whether the assessee had surrendered rights, title and interest in the entire larger land parcel so as to entitle him to deduct indexed cost of acquisition in full; (ii) whether the Assessing Officer was justified in restricting the deduction on a proportionate basis and making the addition of long-term capital gains; (iii) whether the objection regarding violation of natural justice had merit.

Issue (i): Whether the assessee had surrendered rights, title and interest in the entire larger land parcel so as to entitle him to deduct indexed cost of acquisition in full.

Analysis: The consideration of Rs. 33 crores arose from a composite settlement reflected in the consent terms and the conveyance deed. A conjoint reading of the foundational development agreement, possession receipt, consent terms and conveyance deed showed that the assessee's rights were not confined to a smaller carved-out portion but extended over the entire survey number measuring 35,600 sq. mtrs. The documents recorded surrender of all rights, title, interest and possession in the larger land, and the civil suit itself had been instituted for specific performance of the agreement relating to the whole parcel. The assessee's rights were therefore treated as a distinct capital asset acquired through development and possessory rights.

Conclusion: The assessee was held entitled to claim the indexed cost of acquisition with reference to the entire larger land, and the surrender was treated as covering the whole parcel, not merely a part.

Issue (ii): Whether the Assessing Officer was justified in restricting the deduction on a proportionate basis and making the addition of long-term capital gains.

Analysis: The proportionate restriction based on the area of 13,967.50 sq. mtrs. was found to rest on a misreading of the transaction and an isolated reading of select recitals. Since the assessee's extinguished rights related to the entire larger land, the cost could not be artificially scaled down by applying a fraction derived from the later conveyance of only one portion. The addition made by recomputing long-term capital gains on that basis was therefore unsustainable.

Conclusion: The addition of Rs. 20,28,10,757/- was held to be not sustainable and was deleted.

Issue (iii): Whether the objection regarding violation of natural justice had merit.

Analysis: The record showed multiple hearings, including video conference hearings, a detailed show cause notice and a speaking assessment order. The grievance that the assessment was made in breach of natural justice was not supported by the record.

Conclusion: The natural justice ground was rejected.

Final Conclusion: The Revenue's appeal failed on the substantive capital gains issue, while the procedural objection was rejected; the deletion of the addition was sustained.

Ratio Decidendi: Where contemporaneous settlement documents and conveyance recitals, read as a whole, show that a taxpayer relinquished the entire bundle of rights in a larger property, the cost of acquisition cannot be artificially apportioned by reference to only one physical portion later conveyed to a third party.

Issues: (i) Whether the delay in filing the appeal before the Tribunal deserved condonation on the basis of sufficient cause; (ii) Whether the additions made on account of unexplained investment and differential stamp duty value in respect of the property were sustainable.

Issue (i): Whether the delay in filing the appeal before the Tribunal deserved condonation on the basis of sufficient cause.

Analysis: The explanation for delay was accepted as bona fide, the assessee having depended on a tax practitioner who failed to represent the case and suppressed notices and orders. The Tribunal applied the settled principle that substantial justice should prevail over technical considerations and found no mala fides in the belated filing.

Conclusion: The delay was condoned in favour of the assessee.

Issue (ii): Whether the additions made on account of unexplained investment and differential stamp duty value in respect of the property were sustainable.

Analysis: The Tribunal admitted additional evidence under Rule 29, accepted the source trail for the property payments including bank withdrawals, loan and family agricultural income, and held that the ad hoc confirmation of 1/5th of the investment as unexplained had no basis. On the stamp duty dispute, it found that the fair market value was not to be mechanically equated with the stamp valuation in the facts, especially where the property was alleged to be unauthorised and liable to demolition, and held that the addition was made under the wrong provision for the relevant assessment year. It also accepted that the assessee had shown a reasonable explanation for the source of funds.

Conclusion: The additions were deleted in favour of the assessee.

Final Conclusion: The appeal succeeded in full and the assessed additions and related adverse findings did not survive.

Ratio Decidendi: Where a delay is shown to be bona fide and supported by sufficient cause, and where the assessee establishes a credible source trail together with facts showing that stamp valuation cannot be adopted mechanically, the Tribunal may condone the delay, admit additional evidence, and delete the additions if the revenue's basis is unsustainable in law and on facts.

Issues: Whether the additions deleted by the first appellate authority in respect of revised project cost, allocation of TDR/development rights, GST impact, and profit recognition under the Percentage Completion Method required to be restored for de novo verification.

Analysis: The assessee revised the survey-stage estimates at the return stage on account of change in floor configuration, revised GST regime with denial of input tax credit, and reallocation of TDR/development rights across phases of the project. The Tribunal held that the factual foundation for these revised estimates had not been comprehensively verified by the lower authorities. The impact of GST on construction cost, phase-wise acquisition and utilisation of TDR, the effect of floor-plan revision, and the consistency of revenue recognition with registered agreements and the corresponding cost base were all factual matters requiring detailed examination. It found that neither outright rejection by the Assessing Officer nor acceptance by the first appellate authority without exhaustive verification was justified.

Conclusion: The matter was set aside and restored to the Assessing Officer for fresh adjudication after proper factual verification, and the Revenue's appeals were allowed for statistical purposes.

Issues: Whether the reassessment framed under section 147 of the Income-tax Act, 1961 was valid when the Assessing Officer who issued the notice and completed the assessment lacked jurisdiction over the assessee.

Analysis: The assessee established that the jurisdiction to assess it lay with a different Assessing Officer, and that objection had been raised before the lower authorities. The Tribunal found that the jurisdictional fact was not rebutted. It held that issuance of notice by an officer not vested with jurisdiction is not a mere technical irregularity but a jurisdictional defect affecting the very authority to reopen the assessment. The Tribunal also held that section 292BB of the Income-tax Act, 1961 could not cure a defect in the issuance of notice by an incompetent authority.

Conclusion: The reassessment was held to be bad in law and the assessment order was quashed. The appeal was allowed, and the remaining grounds were not examined as they had become academic.

Issues: Whether an appeal under Section 26 of the Prevention of Money-laundering Act, 2002 could succeed on the ground that the predicate offence was not a scheduled offence at the time of its commission, and whether proceedings under Section 3 of the Prevention of Money-laundering Act, 2002 were barred by Article 20(1) of the Constitution of India.

Analysis: The Tribunal held that the relevant consideration for money-laundering is the date on which the person engages in any process or activity connected with proceeds of crime, not merely the date of the predicate offence. It accepted that the offence of money-laundering is of a continuing nature and that liability may arise where proceeds of crime are concealed, possessed, used, or projected as untainted property after the statutory regime has come into force. It further noted that the appellant had already been convicted in the predicate case and that the ECIR remained unquashed. On these facts, the plea that the predicate offence was not then scheduled did not defeat the proceedings.

Conclusion: The objection based on alleged non-scheduled status of the predicate offence at the time of commission was rejected, and the challenge to the impugned attachment order failed.

Final Conclusion: The appeal was held to be without merit because the alleged laundering activity was treated as a continuing offence governed by the date of the laundering act, not the date of the underlying predicate offence.

Ratio Decidendi: For the purposes of Section 3 of the Prevention of Money-laundering Act, 2002, the relevant date is when the accused deals with proceeds of crime in a continuing process of concealment, possession, use, or projection as untainted property, and not the date on which the predicate offence was committed.

Issues: (i) Whether property acquired before the crime period could still be provisionally attached as equivalent value of proceeds of crime under the Prevention of Money Laundering Act, 2002. (ii) Whether the appellant had shown any basis to interfere with the confirmed attachment order in view of the pending criminal case and the material linking him to the alleged smuggling activity.

Issue (i): Whether property acquired before the crime period could still be provisionally attached as equivalent value of proceeds of crime under the Prevention of Money Laundering Act, 2002.

Analysis: The Tribunal relied on the later judicial interpretation of the expression "proceeds of crime" to hold that the definition is broad enough to include not only tainted property but also property of equivalent value where the original proceeds are not traceable. It accepted that the legislative scheme permits attachment of other property of equivalent value even if such property was acquired prior to the crime period, where the proceeds of crime are unavailable.

Conclusion: The challenge to attachment on the ground that some properties were acquired before the crime period was rejected.

Issue (ii): Whether the appellant had shown any basis to interfere with the confirmed attachment order in view of the pending criminal case and the material linking him to the alleged smuggling activity.

Analysis: The Tribunal noted that the criminal case against the appellant was still pending and there was no order of discharge or acquittal. It also accepted the respondent's case that the appellant was alleged to be involved in the smuggling operation and that the attachment was based on proceeds of crime or property of equivalent value. In the absence of material establishing innocence or any legal infirmity in the attachment, no ground for interference was made out.

Conclusion: The attachment order was upheld and the appellant's challenge failed.

Final Conclusion: The appeal did not succeed and the confirmation of provisional attachment remained undisturbed.

Ratio Decidendi: Under the Prevention of Money Laundering Act, 2002, property of equivalent value may be provisionally attached when the proceeds of crime are not traceable, even if the property was acquired before the crime period.

Outcome: Matter listed for further hearing on 21.05.2026 under the heading "For Orders".

Issues: (i) Whether the delay of 171 days in filing the appeal deserved condonation. (ii) Whether the addition made under section 56(2)(x) of the Income-tax Act, 1961 on account of difference between the consideration declared by the assessee and the stamp duty valuation could survive when the difference between the consideration and the DVO-determined value was within the 10% safe harbour limit.

Issue (i): Whether the delay of 171 days in filing the appeal deserved condonation.

Analysis: The explanation for delay was supported by a sworn affidavit and was found to be bona fide, reasonable, unintentional, and plausible.

Conclusion: The delay was condoned in favour of the assessee.

Issue (ii): Whether the addition made under section 56(2)(x) of the Income-tax Act, 1961 on account of difference between the consideration declared by the assessee and the stamp duty valuation could survive when the difference between the consideration and the DVO-determined value was within the 10% safe harbour limit.

Analysis: The DVO determined the fair market value at Rs. 6,11,69,000 against the declared consideration of Rs. 5,60,00,000, leaving a difference of 9.23%, which fell within the permissible 10% variation. The Tribunal applied the view that the enhanced safe harbour limit from 5% to 10%, introduced by the Finance Act, 2020, operates retrospectively.

Conclusion: The addition was deleted and the issue was decided in favour of the assessee.

Final Conclusion: The appeal succeeded on merits after condonation of delay, and the impugned addition was set aside.

Ratio Decidendi: Where the difference between the declared consideration and the determined value remains within the 10% safe harbour margin, the deeming addition cannot be sustained, and the enhanced tolerance limit is to be applied retrospectively.

Issues: Whether penalty under section 270A of the Income-tax Act, 1961 was sustainable where depreciation claimed by a charitable trust was disallowed under section 11(6), but after giving effect to the quantum appellate order the assessed income remained Nil and no tax was ultimately payable.

Analysis: Penalty under section 270A is not an automatic consequence of every disallowance. For the provision to apply, the statutory conditions of under-reporting must exist in a real and legally relevant sense. Where the assessee is a charitable trust governed by section 11, the disallowance of depreciation does not by itself establish under-reporting if the ultimate assessment, after considering the appellate relief under section 11(2), results in Nil income and no tax liability. In such a situation, there is no present or future tax advantage, no reduction of loss with statutory consequence, and no demonstrated tax effect arising from the claim. A disallowed claim may be corrected in assessment, but penalty requires the further element of a statutory mischief contemplated by section 270A. The penalty provision must therefore be applied strictly and not mechanically on the basis of an inadmissible claim alone.

Conclusion: The penalty under section 270A was not leviable and was rightly deleted.

Ratio Decidendi: Where disallowance of a claim in the case of a charitable trust leaves the assessed income at Nil and creates no tax liability or tax advantage, the foundational requirement of under-reporting under section 270A of the Income-tax Act, 1961 is absent and penalty cannot be sustained.

Issues: Whether rejection of the application for registration under section 12AB was sustainable, and whether the application ought to be treated as one for registration as a religious trust and remitted for fresh consideration.

Analysis: The statutory scheme under section 12AB(1)(b) requires the Commissioner to satisfy himself about the objects of the trust, the genuineness of its activities, and compliance with other applicable law. On the material placed, the assessee's objects, its activities, the nature of its training and formation work, the registrations already reflected as a religious association, and the documentary material regarding religious instruction supported the claim that it functioned as a religious seminary. The financial objections and receipt-pattern issues were held to be matters for assessment and not determinative of genuineness for registration purposes. The application was found to have been wrongly approached as one for a charitable institution, and the error in description was treated as inadvertent.

Conclusion: The rejection of registration was not sustained, and the matter was remitted to the Commissioner to decide afresh by treating the Form 10AB application as one seeking registration as a religious trust after granting reasonable opportunity of hearing.

Final Conclusion: The assessee obtained a limited appellate relief, with the refusal set aside in substance and the registration question sent back for fresh adjudication in the correct religious-trust framework.

Ratio Decidendi: For registration under section 12AB, the authority must examine the objects and genuineness of activities in their true character, and a misdescription of the nature of the trust cannot justify rejection where the record otherwise supports the correct religious character and the remaining financial issues are matters for assessment.

Issues: Whether penalty under section 271AAC of the Income-tax Act, 1961 could be sustained merely because an addition was made under section 68 of the Income-tax Act, 1961, and whether such penalty was automatic.

Analysis: The unsecured loans were reflected in the books of account, and the addition under section 68 arose from the assessee's failure to furnish complete supporting details in the assessment proceedings conducted ex parte under section 144 of the Income-tax Act, 1961. The statutory language of section 271AAC confers discretion by using the expression "may", and penalty cannot follow mechanically from the making of an addition. Penalty proceedings are quasi-criminal in nature and require a higher threshold than assessment proceedings. On the facts, the default at best disclosed a technical breach and not concealment warranting automatic penalty.

Conclusion: The penalty under section 271AAC of the Income-tax Act, 1961 was not exigible and was deleted.

Issues: (i) Whether the petitioners were supplied written grounds of arrest in compliance with the governing criminal procedure and GST arrest provisions; (ii) whether the petitioners made out a case for bail in a prosecution alleging fraudulent availment and passing of input tax credit through fake invoices.

Issue (i): Whether the petitioners were supplied written grounds of arrest in compliance with the governing criminal procedure and GST arrest provisions.

Analysis: The order applies the settled principle that written grounds of arrest must be furnished to the arrested person, and distinguishes those grounds from the general reasons for arrest. On the record, the petitioners had been summoned and examined during investigation, written grounds of arrest accompanied the arrest papers, and the materials placed before the Court did not prima facie show that the documents were not furnished at the time of arrest.

Conclusion: The objection based on non-furnishing of written grounds of arrest was rejected.

Issue (ii): Whether the petitioners made out a case for bail in a prosecution alleging fraudulent availment and passing of input tax credit through fake invoices.

Analysis: The allegations involved a large-scale economic offence supported by statements under investigation, electronic material, seized devices, forensic analysis and WhatsApp chats. The Court found prima facie material connecting the petitioners with operation of fake firms and issuance of invoices without actual supply of goods, and also noted the magnitude of the alleged offence and the alleged non-cooperation during investigation.

Conclusion: Bail was declined.

Final Conclusion: The petitions were not found fit for enlargement on bail and the prosecution was permitted to continue on the basis of the prima facie material collected during investigation.

Ratio Decidendi: In a bail proceeding arising from a documentary and electronic evidence-based economic offence, written grounds of arrest must be furnished, but where such compliance is prima facie shown and substantial material links the accused to the alleged fraudulent activity, bail may be refused.

Issues: Whether the assessee could be treated as an assessee in default under section 201(1) of the Income-tax Act, 1961, and charged interest under section 201(1A), for non-deduction of tax at source on Leave Fare Concession payments where the employees' travel included a foreign leg, despite interim judicial directions restraining deduction.

Analysis: The issue on the availability of exemption under section 10(5) for travel involving a foreign leg stood concluded on merits against the assessee. The dispute before the Tribunal was confined to the liability under section 201 for the relevant period. The Tribunal held that the assessee was bound by the interim directions of the High Court then in force and that the obligation to deduct tax under section 192 had to yield to those binding judicial orders. However, the Tribunal ultimately preferred to follow the Supreme Court's decision on the substantive tax position and treated the assessee as having had the statutory obligation to deduct tax. In the absence of a specific interim order applicable to the assessee before it, the Tribunal declined to exempt it from the consequence of non-deduction.

Conclusion: The assessee was held liable to be treated as an assessee in default under section 201(1), and the consequential interest under section 201(1A) was sustained.

Final Conclusion: The appeal failed, and the demand raised for non-deduction of tax at source on the impugned Leave Fare Concession payments remained undisturbed.

Ratio Decidendi: Where the substantive exemption claim is rejected on merits and no binding interim judicial restraint specific to the assessee is shown to override the withholding obligation, the assessee may be treated as an assessee in default under section 201(1) with consequential interest under section 201(1A).

Issues: Whether the disallowance of exemption claimed under section 54EC of the Income-tax Act, 1961, on the ground that the second investment in specified bonds was made beyond six months from the date of transfer, was justified, and whether the matter required verification by the Assessing Officer.

Analysis: The claim turned on the factual plea that the specified REC bonds were not available for subscription during the relevant period after the first investment, and that the later investment was made only when the bonds became available. In view of this contention, the correctness of the disallowance could not be finally determined without verification of the availability of bonds and the timing of investment. The Tribunal also noted that the dispute arose from the processing of return under section 143(1) and the subsequent rectification proceedings under section 154 of the Income-tax Act, 1961.

Conclusion: The matter was set aside to the jurisdictional Assessing Officer for necessary verification, and the assessee obtained only partial relief.